PFPI-BiomassIsTheNewCoal-April-2-2014

company was permitted to use non-EPA emissions factors for HAPs, which dramaticallyunderestimate emissions compared to the EPA-sanctioned emissions factors.North Star Jefferson, Wadley, GAWhat: 312 MMBtu/hr fluidized bed boiler; 25 MW (gross).Estimated CO 2 emissions (tons per year): 275,000Permitted emissions (tons per year): NOx: 249 CO: 249 PM 10 fil : 21 SO 2 : 249Status for NOx, PM, and CO: Synthetic minor source (avoided PSD)Status for HAPs: Synthetic minor sourceFuel: wood, shredded tiresConstruction and demolition wood or other waste allowed as fuel? Initially yes; as permitted, no.Use of NCASI or other non-EPA factors to estimate HAPs? YesNotes: The facility is located in an area with large existing pollution sources, including woodburners.No pre-construction air quality modeling has been conducted. It is beingdeveloped by a pro-forestry non-profit organization, the U.S. Endowment for Forestry andCommunities, but the developer has stated that burning tires is important to the success ofthe facility. As for other biomass facilities permitted in Georgia, this facility used non-EPAsanctioned emissions factors to come to the conclusion that it is a minor source for HAPs.Initial stack tests are required to establish emissions rates for certain HAPs.Piedmont Green Power, Barnesville, GAWhat: 657 MMBtu/hr stoker boiler; 54.5 MW (net).Estimated CO 2 emissions (tons per year): 564,192Permitted emissions (tons per year): NOx: 228 CO: 227 PM 10 fil : 86 SO 2 : not specStatus for NOx, PM, and CO: Synthetic minor source (avoided PSD)Status for HAPs: Synthetic minor sourceFuel: “Biomass shall consist of wood wastes in chip or in shredded form from timber harvesting,pre-commercial thinning of forest plantation stands, harvesting non-commercial, dead ordeformed species for fuel purposes and land clearing activities (limbs, tops, stumps andnon-commercial trees), and may also include peanut hulls, pecan shells, cotton stalks,lumber and pallet wood wastes (unpainted/untreated only) and similar woody biomass.”Construction and demolition wood or other waste allowed as fuel? YesUse of NCASI or other non-EPA factors to estimate HAPs? YesNotes: While this facility claims to be a synthetic minor source for HAPs, and the permit states thatpotential emissions of HAPs are greater than 25 tons, the permit contains no testingrequirements other than a one-time test for HCl. The permit would thus likely be deemedunenforceable under Clean Air Act requirements, although the omission might be rectifiedwhen the Title V operating permit is issued. This facility was awarded $49.5 million in“clean” energy funding from the federal government, as a 1603b award that converts thefederal renewable energy incentive tax credit to a cash grant.74